US 322. United States District Court, Southern District of New York, 16 August 1999
Related topics
102
The court discusses which awards are considered non-domestic even if rendered in the State of enforcement (international element, lex mercatoria).
Arbitral award not considered as domestic (paragraph 1)
500
The court discusses the overall scheme and/or pro-enforcement bias of the Convention.
Grounds for refusal of enforcement in general
518
Public policy: The court discusses the meaning of (international as compared to domestic) public policy, generally defined as the basic notions of morality and justice of the enforcement State.
Paragraph 2 - Distinction domestic-international public policy
519
Public policy: The court discusses cases in which the subject matter of the award was not arbitrable in the enforcement State on public policy grounds.